CPSIA – Hey, Republicans, THANKS SO MUCH for that Pledge for America

Did anyone notice how the CPSIA Amendment (HR 2715) went to the House floor in the middle of the night on a Sunday after closed door horse trading out of the public eye, and was voted on early the next day designated as a “noncontroversial bill” (Monday, August 1).  The amendment didn’t go through a mark-up hearing and was only published a few hours before the vote.  The law includes some surprises, too, as one might expect on a bill emerging from a smoke-filled room.  Naturally, the Senate considered it and put it up for a voice vote in even less time.  How many Members of Congress bothered to read the bill before voting on it?  How many Members of the responsible House and Senate committees read it before voting on it?  Your guess is as good as mine. You may recall that the Republican Party published “A Pledge to America” in 2010 ahead of the Medterm elections, with the nifty subtitle “A new governing agenda built on the Priorities of Our Nation, the Principles We Stand for & America’s Founding Values”.  Impressive. The Pledge includes a section starting on page 33 called “A Plan to Reform Congress and Restore Trust”.  Restore trust – I am all for that!! On page 35 of this document , the Republicans make the following ”promise”: ” Read the Bill    We will ensure that bills are debated and discussed in the public square by publishing the text online for at least three days before coming up for a vote in the House of Representatives. No more hiding legislative language from the minority party, opponents, and the public. Legislation should be understood by all interested parties before it is voted on. ”   [Emphasis added] Correction:  They’ll do all that stuff unless they don’t.  And in the case of the CPSIA Amendment, well, come on, don’t be such a rule follower . . . .

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CPSIA – Hey, Republicans, THANKS SO MUCH for that Pledge for America

CPSIA – As Predicted, the Senate Adopted House Bipartisan Bill Amending CPSIA

After three years of warring, Congress has finally passed an amendment to the CPSIA.  HR 2715 was approved by the Senate this evening by voice vote. This is expected to be the last legislative relief (thusfar the only legislative) relief from the CPSIA. 

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CPSIA – As Predicted, the Senate Adopted House Bipartisan Bill Amending CPSIA

CPSIA – The Senate Moves In the Direction of the House Bill

Confidential discussions are underway for Senate Democrats to accept the House bill amending the CPSIA which passed today 421-2.  The pressure being applied relates to the consequences on U.S. retailers from the retroactive application of the 100 ppm lead standard. If the House bill is accepted by the Senate Dems, it will no doubt be hotlined for quick passage by voice vote, and then this ugly process will be over. With the pending exclusion under the bill of ATV’s, bikes and books (the chosen winners, including the remarkable free pass on metal component testing by bicycle manufacturers), the rest of us (the chosen losers) will remain under the thumb of both the CPSIA and the Dem-controlled CPSC.  I would note that we, the chosen losers, are no doubt the people Inez Tenenbaum refers to as “certain cynical special interests”.  If you disagree with her agenda, you must be a “cynical special interest”, it seems to me.  Thanks to Jan Schakowsky for this nifty idea! I was asked earlier today if I supported the House bill (which subsequently passed 421-2).  I replied that the bill is good for us, but not good enough.  It does not address the big issues imperiling companies like ours, and furthermore, incorporates ineffective provisions on several fronts which are only there to bolster Dem chances for reelection.  That said, I advised supporting the bill because frankly what choice did we have anyway?  The impact of this bill, I noted, is like being offered a better cell in jail.  You gotta take it, if only for the view. But you’re still in jail all the same.

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CPSIA – The Senate Moves In the Direction of the House Bill

CPSIA – The House Answers with its Own (Bipartisan) Suspension Bill

The Republicans and Democrats on the House Energy and Commerce Committee have apparently suddenly agreed on a new 29-page draft CPSIA Amendment .  This is a modification of ECADA and is probably the best that the House Republicans could extract from the Dems.  It is also part of a game of chicken between the House and Senate on how to amend the CPSIA.   The bill is sponsored by Mary Bono-Mack and G.K. Butterfield, meaning that it is a bipartisan bill.  It will proceed to the House floor for a vote tomorrow, cannot be amended and will only  pass by 2/3 majority vote.  It could be a voice “consensus” vote and will likely pass without opposition given its bipartisan character. A quick review of this amendment: a.  100 ppm lead standard is made prospective. b.  Functional Purpose exception process remains part of the amendment.  [I have written extensively on how this provision is a sham .  I haven't changed my mind.] c.  ATV exception is included.  This is death knell for any hope of later CPSIA amendments. This signals the end of the road. d.  The terms of the bike stay are made into law.  They also get a really sweet deal – as far as I can tell, they don’t have to test metal components anymore.  That provision is buried on page 19 in the book exception section.  All the better to sneak it through.  Nice for them . . . but no word as to why we must test metal components.  Too bad for us, I guess. . . . e.  Resale goods exception is included. f.  Testing rules are now based on “representative” samples, not “random” samples.  The rest of the provision is based on the Eshoo amendment requiring further “inquiry” on reducing costs of third party testing.  The Eshoo model still requires “assuring compliance” with the lead standards.  This is the big dollar issue, as everyone knows, and is the one issue that touches everyone, all the ordinary businesses.  This provision is a punt and offers little prospect for future relief.  This provision is a huge time-waster and will never result in anything useful because the standard for relief is in the context of “assuring compliance”.  It also calls for more business “instruction” like that found in the current draft of the “15 Month Rule”.  [The status of the 15 Month Rule is not apparently addressed and may still emerge from the agency to bite us later this year.]  The authors of the 15 Month Rule draft rule know exactly zippo about the real world and if we are ever supposed to follow their sage dictates, the losses will mount . . . fast.  In any event, this Commission will never feel comfortable with anything less than prophylactic assurance, injury statistics be damned.  I hate this provision because I don’t trust the CPSC Commission under current leadership. Notably, this provision does not stay compliance with the testing rules due to go off stay at the end of the year pending resolution of the Eshoo inquiry.  Congress has not dictated that the stay be extended, and believe me, it won’t be.  The reasoning behind this provision escapes me. g.  Small batch manufacturers receive minimal relief (” reasonable methods to assure compliance “).  The real sham part of this is the tantalizing prospect that the CPSC will actually deliver on this demand for testing relief.  Call me a cynic, but they have received testimony out the wazoo for three years on this topic, and have yet to find a way to “help” the remaining micro-businesses in the market.  And the reason we should believe they will make a afety testing discovery in the future?  Your guess is as good as mine.  They won’t. Small batch manufacturers have to register before benefiting from this wonderful “relief”.  The registration requirement is deeply offensive to me and really shames Congress and the agency.  What did these little companies do to deserve this treatment?  What makes the House (Dems) think this is a good idea?  It smacks of 1984 and is utterly detached from any rational assessment of risk.  Do small batch manufacturers have an exceptionally bad safety track record meriting this kind of surveillance?  Of course not.  That they would accept or even support this treatment is shocking to me.  In any event, no relief is offered to any company with gross revenues in excess of $1,000,000, so it’s really just for the benefit of the really micro micro-businesses.  It won’t benefit me even for small unit volume items we currently sell – our top line makes us ineligible for any possible relief.  Happy registering, little guys! h.  Ordinary books and printed materials get a pass. i.  Durable Nursery Products standards provision (not reviewed). j.  Phthalates standard applied only to “plasticized” components and not to inaccessible components.  Guess that means no more testing of paper, wood and metal. k.  Authority to exclude items from tracking labels provision is given to the CPSC based on practicability.  This is promising although the Dem hanging judges on the Commission have yet to make a single decision that saved a business a dollar for any reason. Don’t hold your breath. l.   Database rules are tweaked in a meaningless way consistent with the Markey proposal on database.  NO relief offered. THERE IS NO RELIEF GIVEN TO EDUCATIONAL MATERIALS.  Thanks, Congress.  I am glad my kids are out of elementary school by now. That’s it, more or less.  Hope you like it, that’s all you’re going to get.

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CPSIA – The House Answers with its Own (Bipartisan) Suspension Bill

CPSIA – Rumorville on Pryor Bill

A little bird tells me that some people have verified that the the Pryor bill to amend the CPSIA has been “hotlined” in the Senate as a step to immediate passage.  Other people have gone silent or have been unable to verify, so it’s not an entirely clear situation.  “Hotlined” bills are on track for a unanimous consent vote.  I gathered this explanation from Republican Committee on Rules site on hotlining: ” The Senate has largely institutionalized its unanimous consent process. On major pieces of legislation, the Majority or Minority leader may force a Senator from the other party to object to a bill’s consideration in the absence of a unanimous consent agreement. Similarly, the Senate will hotline a bill when it is ready to be considered under a unanimous consent agreement. Under the hotline process, the Senate cloakrooms notify Senators of upcoming bills that may be considered under unanimous consent to provide them with a final opportunity to object .” It’s all rumor at this time, but this suggests that someone wants to get something done now.  While the Pryor bill is imperfect as drafted, it’s better than nothing, and if there is a chance of a conference bill later, the possibility of a better bill is not yet dead . . . before we all die.

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CPSIA – Rumorville on Pryor Bill

CPSIA – Northup Lashes Out at Majority for Disregarding Executive Order

Letters to the Editor Wall Street Journal July 26, 2011 CPSC Should Follow Obama’s Policy As one of the minority (Republican) commissioners on the Consumer Product Safety Commission who voted against finding that it was technologically feasible to lower the lead content in all children’s products from 99.97% lead free to 99.99% lead free, I appreciate your July 20 editorial ” Toying with Deregulation .” You accurately paint a grim picture of the commission’s disregard for President Obama’s appeal that regulatory agencies promote “economic growth, innovation, competitiveness and job creation.” But you omit the even more disturbing evidence that the commission majority twisted the language of the Consumer Product Safety Improvement Act and ignored the evidence before it in order to reach a predetermined outcome. As the majority proved with its 100 ppm vote, it will take much more than an executive order to stop an agency bent on imposing its radical agenda without regard for the economic consequences. See www.cpsc.gov/pr/northup07202011.pdf . Anne M. Northup Commissioner CPSC Washington

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CPSIA – Northup Lashes Out at Majority for Disregarding Executive Order

CPSIA – Not to State the Obvious, but the Debt Ceiling Fiasco Imperils ECADA

Among the many reasons for despondency at this time of national gridlock is that the Washington national debt standoff likely signifies the demise of ECADA (the pending CPSIA Amendment).  A week from this Friday is the last work day before Congress’ all-important summer recess.  [As you know, Congress needs its R&R.]  The CPSIA will remain unamended unless a bill moves through Congress by then.  You don’t need to be a seasoned Washington vet to see that Congress ground to a halt while the national debt food fight is going on.  With the likely pressure of world market volatility, U.S. credit rating downgrades and other homegrown massive financial calamities, and you have a recipe for Congress’ attention being somewhere besides the CPSIA.  With the President and his minions playing the market manipulation card (Daley and Geithner were dispatched to the Sunday talk shows to spread their gloomy prediction of market cracks on Monday), the ability of Congress to focus on its actual work is just about nil now.  Mine certainly is, too. It will be the ultimate irony if the debate over the size of our government is what wins day for an engorged CPSC focusing on fake health crises as directed by the CPSIA.  Victory to Rachel Weintraub, Henry Waxman and Bob Adler all because our national leaders can’t decide how much to spend beyond our national means?  Three years of fighting may end up on the rocks, simply because of bad timing. If ECADA does not become law before August 14, the 100 ppm lead standard will be retroactive, the THIRD such scr*wing imposed on us by the soulless bureaucrats at the CPSC since August 2008.  Oh yes, I know, they have no choice.  Woe is me, they feel so badly about it, but what can you do??? Tell that to our employees, our suppliers, our dealers and the millions of families, schools and teachers who depend on our company and its products.  Hey Dems, why not finish the job with a big tax increase, too?!  Stay tuned.

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CPSIA – Not to State the Obvious, but the Debt Ceiling Fiasco Imperils ECADA

CPSIA – NAM Ad In The Hill Supporting Passage of ECADA

From The Hill Newspaper, dated July 21, 2011: The time left to Congress to act on amending the CPSIA before the 100 ppm lead standard boom crushes more businesses and jobs is only 24 days .  [ Html version of the ad ]  This includes the time to get through the Senate, then conference, then to the President for signature.  Not a lot of time . . . and par for the course for this government, I suppose.  Will they act in time?  I certainly hope so but with Henry Waxman doing his evil best to prevent any progress on this issue, I don’t have high expectations.  Let’s hope some Democrats still have a conscience.

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CPSIA – NAM Ad In The Hill Supporting Passage of ECADA

CPSIA – Sound Bite Justice

Today the CPSC Commission voted 3-2 to impose the 100 ppm lead standard retroactively as of August 14, 2011 , having concluded that there are no materials or products that the CPSC staff could identify for which this level of lead is not “technologically feasible”.  This vote has been long predicted and anticipated.  The entire meeting was conducted in a thoroughly partisan manner, with sharp dividing lines between Dems and Republicans.  What-a-shock.  I experienced a range of emotions watching this two-hour hearing.  None of them were surprise.  I experienced some boredom, as the debate was so predictable and so repetitive of past meetings.  Many self-serving remarks by the Dem zealots.  I experienced a mild sense of hopelessness, as it is clear that the Dems are unreachable. I experienced rising exasperation over their refusal to listen or consider data – unless it agrees with pre-existing agendas and alliances.  It is hard to not feel you are appearing before the Hanging Judge.  I won’t attempt to analyze what was really going on today, you already know it.  The posturing was sickening among the Dems.  That said, you deserve some flavor of the event.  Here are a few tidbits for your amusement or annoyance: She’s just the nicest! Inez Tenenbaum explained that the 100 ppm standard would have gone into effect if the CPSC had not chosen to decide the question of “technological feasibility”.  As she sees it, ” this [decision] is a courtesy to people .” What, Boeing isn’t covered by the CPSIA?! After vigorously stating her case on the cost-benefit analysis of this rule and condemning the possible adoption of this rule as a violation of the recent Executive Order applicable to the CPSC, Ms. Nord restates the obvious. Unfortunately, the power of her logic was lost on at least three of her colleagues by my estimate:  ” Just because a material is out there for a jet plane, doesn’t mean that it’s appropriate for a toy plane .”  No! Is that a promise, Bob? Defending caveman logic to his followers, Bob Adler rebuffed the Executive Order argument and the order of the person who appointed him to his post:  ” This is not a new Executive Order . . . . [They] said could you at least do a plan for economic analysis and I do think that we are planning on doing that and we have done that in the past. It says “to the extent permitted by law” we should do cost-benefit analysis. And I just wanted to say over my dead body would I agree to do the kind of cost-benefit analysis that is contained in Section 9 of the [CPSA]. That is paralysis by analysis. If you look at the data . . . nine [CPSC] standards in 30 years using those procedures. I am not against cost-benefit analysis; I am definitely against the kind of cost-benefit analysis that’s contained in our statute. Section 101 does not EXPLICITLY bar a cost-benefit analysis but it effectively does so .”  [Emphasis added] I find this rather interesting as he challenged me on February 16 with the question of whether I recommended that he violate the law.  It was a tense moment – he was trying to corner me into telling him to spurn his Congressional mandate.  Nevertheless, it is appears that Bob can pick and choose which laws bind him and which do not.  That shouldn’t surprise anyone who went to law school.  Law school profs always know the right answer, even if it makes no sense to anyone but themselves.  They care sooooo much, they really feel our pain . . . . Ms. Tenenbaum set the records straight on the purity of her good intentions:  ” I so believe that we have been diligent in looking at the marketplace and surveying materials. We have admitted it would be an extra cost to some companies and been out front. But, again, ‘technological feasibility’ the definition is not ‘economic feasibility’. Not that I don’t sympathize with small business owners and that is why we have worked on other rules [like the component part rule]. We are trying to be as flexible as possible and work with small businesses and the industry to accomplish what Congress mandated for us to do .” I know it’s just a detail but in the last three years, what exactly has this “effort” achieved?  Oh yeah, I forgot about Neal Cohen – we can cry on his shoulder!  In fact, Ms. T. closed the event with the offer that Cohen has his box of Kleenex ready for you whenever you need him. Somebody’s getting the shaft, let the record reflect. Nancy Nord noticed something the Dems must have missed:  ” You know, one of the things that is of concern to me is that the penultimate recommendation from the staff here is that ‘complying materials APPEAR to be commercially available for most products.’ Listen to the hedge words there in the staff recommendation. They ‘appear to be’? Well, let’s find out for sure and let’s do it on a product category basis. ‘Most products’? Well, what about the ones that can’t meet it? That’s our responsibility as [regulators], colleagues .” Hmmm.  Professor Adler grades the final exam. Bob Adler was in top form today.  The “over my dead body” remark was just an appetizer.  He went on to inform us that comment letters which arrive late are not operative, especially if they did not properly read his mind on what he wanted to see: ” I do want to also comment on some of the last minute submissions we got from our friends in industry, and I always appreciate those comments and I do consider a lot of these folks to be good friends both of this agency and of mine. But it’s really hard to take it seriously when it comes in at the penultimate or ultimate moment when you’ve had a lot of time to get that kind of information to us . . . . [Recites all the opportunities to comment prior to this hearing.] All of that, if you want to make a point, would have been very helpful especially we’d had the kind of hard quantitative data that SGS and the Hong Kong-American Chamber of Commerce gave us. And I’m going to just make a brief comment = you’re free to do it, it’s not helpful to tell us we’ve read the law incorrectly. I think we’ve read it correctly. I don’t think it’s helpful just to tell us that it’s going to be difficult and more expensive to get compliant materials. I think we know that, I think the staff told us that. What we needed was more hard data demonstrating the points that you’re making because what we really got were a lot of conclusory assertions when what we really needed was some hard quantitative data. And all the hard quantitative data I’ve seen really points in the opposite direction. So I really appreciate all the last minute comments. Too little, too late as far as I am concerned .”  [Emphasis added] This lecture was repeated three times by Mr. Adler unprompted, for reasons best understood by him.  Interestingly, Mr. Adler seems to have forgotten that I presented hard quantitative data on this same topic in my timely-filed 100 ppm comment letter and in my Febuary 16 testimony.  Of course, it did not agree with the SGS or HKACC submissions.  I guess since he found their data useful, mine must have been wrong.  According to his remarks today, I didn’t even submit it, which is rather surprising since it was discussed extensively in the Staff report :  “Learning Resources reported 98.3 percent compliance with the 100 ppm standard for its products, but found this compliance level to be unacceptable because of the difficulty in identifying where the noncomplying components would turn up.” Bob Adler flips his flop. You would think with three repetitions of his condescending lecture on late submissions, that Professor Adler must mean it.  Can’t get a good grade in his class with that behavior, right?  Well, maybe not for the teacher’s pet:  ” One very quick point, well two. One is that the [AAP] study you shared with us, and again thank you so much Commissioner Northup, is a 2005 study. We got a letter last night from the American Academy of Pediatrics reiterating their support for moving down to these levels. . . . ” Bob Adler wings it. . . . In the face of a vigorous attack by a well-prepared Anne Northup on the shoddy scientific data presented by the AAP supporting the “no safe level of lead” assertion, Mr. Adler lapses into hyperbole and fantastic assertions incapable of validation: “It isn’t just the [AAP]. A lot of what they’ve done has been drawn from research done around the world on the effects of lead. I’ll bet there must be ten thousand, I know there are thousands and thousands of studies on lead, all of which point to the very severe toxic effects associated with [these products] .” Mother knows best! In a truly shocking display of personal preference substituting for appropriate policy and regulation, Ms. Tenenbaum decided that we don’t need recycled materials in children’s products because who would want them anyway?  ” The scientific community has shown us over and over again that lead is cumulative and so I think there are safety benefits in reducing the exposure to lead and the accumulation of lead in the body. Also, I don’t know that parents are interested in having products that their children use, particularly infants and young children, that are mouthable being made of recycled materials, recycled materials that may contain a higher level of lead. Recycled plastic – do you want your child to have a recycled pacifier? Well, that is why Congress has set these strict limits.” [Full disclosure, we recently won a toy industry award for environmentally-friendly toys made of recycled plastic.  No one has objected to them to my knowledge, and believe me, they are wonderfully and thoroughly tested for compliance.] And the support for Ms. T’s bald assertion is . . . what?  Did she find something in the legislative record?  Is there some verbiage in the law?  I have not heard this previously from anyone at the CPSC but notably I have repeatedly noted that the CPSIA will be the death of recycled materials in children’s products .  Still, Ms. T’s logic is irresistible – she is there to figure these things out for us and certainly knows best.  After all, she loves children, probably much more than any of us. She cares.  What else do you need to know?  With her power to impose policy, her preferences will become our marketplace.  Brave New World, courtesy of the Nanny Staters. Tenenbaum says you can ALWAYS file for an exemption! Ms. T. reminded the audience at least four times that if they wanted to, they could ALWAYS file for an exemption if they can prove their product or material can’t be made to the new standard subject to the non-economic technological feasibility test.  The door is always open . . . . This promise seems to be in denial of reality.  Let’s start with the fact that the CPSC staff studied this question for more than a year and concluded, as summarized in a 59-page tome, that EVERYTHING is technologically feasible.  That seems to put us all against the wall when it comes to exemption petitions.  And then there’s the fact that for three years, nobody has been able to get an exemption for anything, regardless of how obvious the case, unthreatening the use or how well-funded the supplicant. Notes Ms. Northup:  ” I just think we should warn the public that it is unlikely that any petition would be accepted and that that is, first of all, for anybody to file it would be far more costly than to just pay for the materials and increase the cost of their products in all likelihood, not to mention the delay they would have in us in actually addressing their petition .” And Nancy Nord speculates that petitions for relief are highly unlikely in any event:  ” I will just tell you, in my conversations with folks out there, there is a feeling that ‘why bother?’ There is a comment weariness, there is a sense that it isn’t worth the candle, and so I guess if you’re not a company that’s either been put out of business or not making the product, you don’t have the money to hire the lawyer to file the petition. So I think that’s just an empty option for most people .” Who do you believe?  Hey, as Ms. T says, the door’s always open even if it’s the door to oblivion. The outcome of the decision to implement the 100 ppm standard was foretold but let’s not forget something important – this is a retroactive rule as implemented today .  Unless Congress acts, we are all in the soup.  Even worse than before.  Call your Congressman and don’t stop until they take action.  Mr. Obama must sign something by August 14 or all hell breaks out . . . again.

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CPSIA – Sound Bite Justice

CPSIA – Fait Accompli

Tomorrow the stage is set for the ultimate triumph of the Waxmanis:  the predicted approval of the 100 ppm lead standard by 3-2 party line vote.  The three Democrats will express regret, saying that Congress forced them to do it, and calling on Congress to let them make this standard prospective only.  They will no doubt also assert that this is good for all of us, given that “there is no safe level of lead”, that old chestnut unsupported by any injury data. No doubt the 100 ppm lead limit will fix all of these imaginary problems.  The Republicans will note the pointlessness of it all, and remind us of the cost of the provision.  Jobs will be lost.  The Republicans will be right, but the Dems have a political agenda to implement, and you will be sacrificed.  Mr. Obama’s Executive Order will not give the Dems pause. After three years, I am numb to this behavior.  The Dem Commissioners are and have always been beyond reach, unimpressed by reason or data.  That comes from a strong conviction of the correctness of their position with no need to reconsider.  As Bob Adler’s testimony at the Oversight hearing on July 7th indicates, the Dems are ever ready to defend the CPSIA faith.  [Check out the testimony given in questioning by the estimable Jan Schakowsky.]  Data, schmata. For those of you who have expended energy, or committed resources, to providing information to the CPSC after three years on this provision (comment letters, testimony, etc.), please note that it was all a set-up.  The decision facing the Commission is whether the 100 ppm lead level is “technologically feasible”. The legislative definition of this term of art does NOT take into consideration cost, perhaps because every life is precious and of infinite value.  It does not matter what it costs to comply, only whether it is somehow possible.  CPSC Staff confirms that everything can be made without lead using this definition however absurd.  So the Dems have no reason to vote against the new standard.   No reason . . . .   Consider the views of the American Apparel and Footwear Association in a letter dated July 11, 2011 on this topic: “We strongly urge the Commission to declare that it is not technologically feasible to meet the 100ppm standard for the simple reasons that:  (a) it is impossible to meet a standard retroactively; (b) compliance cannot be assured because of continued issues with material variability, especially with metals; (c) compliance is complicated by the regulatory uncertainty generated by the technological unfeasibility issue as well as the ongoing delay in the so-called “15-month rule”; (d) the new standard will impose significant costs on manufacturers, costs which disproportionately affect smaller companies; and (e) inter-lab variability, especially at the lower limits, make consistent compliance impossible.” Details, details – the Dems DON’T CARE.  Tomorrow the Commission will enact an egregiously out-of-whack rule from a cost-benefit standpoint a mere two days after Obama ordered the CSPC by name to review all rules for being overly burdensome.  Yawn.  After three years of this, what else would you expect?

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CPSIA – Fait Accompli

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